Privacy Policy
This Privacy Policy describes how Byram Healthcare, LLC ("Byram Healthcare," "we" or "us") collects, uses and discloses information about you that you provide through the ByramConnect website and mobile applications (collectively, the “Site”)). This Privacy Policy does not apply to information we collect through websites, applications, offerings, products or services that do not link to this Privacy Policy. Certain parts of the Site are available only to individuals who use ByramConnect, a prescribed software product for people with type 1 and type 2 diabetes, and who create a user account (“Users”).
If information you provide through the Site is protected health information that is subject to HIPAA, we will use and disclose that information only as stated in our Notice of Privacy Practices. If you have any questions about which policy applies to information you provide, please contact us at the contact information provided in the “Contact Us” section below.
If you do not want us to collect, use or disclose information about you as described in this Privacy Policy, then you should not use the Site. By using the Site, you are accepting the practices set out in this Privacy Policy and our Terms of Use.
INFORMATION WE COLLECT AND HOW WE USE THAT INFORMATION
We may collect different types of information about you based on your use of our Site and our business relationship with you.We may collect the following types of information about you:
Contact and demographic Information,such as your name, address, telephone number, e-mail address, age and gender.
Technical and Usage Information, such as information about your device, equipment performance and Site usage. We may also automatically collect certain technical information relating to you, which your web browser automatically sends whenever you visit a website on the Internet, or which is collected when you use a mobile application (see “Online Activity Tracking” below for more information). For example, we may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your device, to help us analyze how you use our Site. You can find out more about how Google uses data by visiting “How Google uses information from sites or apps that use our services”, located https://policies.google.com/technologies/partner-sites.You can opt out of Google Analytics by installing Google’s opt-out browser add-on (https://tools.google.com/dlpage/gaoptout).
Location Data, such as while navigating the Site your mobile device or browser may share your location data through WiFi or GPS. We may collect this information based on the settings of your phone and browser.
Health, insurance and financial Information,, such as information about your medical condition, medications you are taking, and health insurance information.
We collect information in three primary ways:
You give it to us, including in instances where you may choose to link other sources of information to the Site, such as through a fitness tracking application or device;
We collect it automatically when you visit the Site, such as through tracking tools like cookies, pixels, and web beacons;
We obtain it from other sources, such as your health plan, employer or doctor.
We may combine personal information we obtain. For example we may combine information that we have collected online with information that we have collected offline, such as information collected between you and our support team. We may also combine information that we have collected across other third party sites or from other third parties with information we already have. Finally, we may combine information we receive across devices that you use to access the Site.
We may use the information we collect in a variety of ways, including to:
Provide you with a better customer experience when you use our Site;
Provide services to you, and to respond to your questions or concerns;
Communicate with you regarding service updates, offers, and promotions;
Deliver customized content that may be of interest to you, including information about products or services that may be relevant to your care or settings of care;
Maintain the security of our products, services and systems;
Protect our rights, property, and safety or the rights, property, and safety of others;
Improve our level of service or develop new products or services;
Provide notifications on the latest site features; and
Comply with our legal obligations.
ONLINE ACTIVITY TRACKING
We collect information about your activity on the Site for a number of purposes using technologies such as cookies, flash cookies, web beacons, widgets and server log files. To limit the use of flash cookies from our Site, simply right-click on our website and adjust the Adobe Flash Player settings bar under “Local Storage” to your desired setting. Since cookies are now used as industry standard, most Web browsers automatically accept cookies, but you can usually change your browser to decline them. If you prefer not to enable cookies, you may choose to disable them; however, please note that certain features of our products and services will not be available to you once cookies are disabled. Some web browsers have a “Do Not Track” feature. This feature allows you to tell websites you visit that you do not want to have your online activity tracked over time and across websites. These features are not yet uniform across browsers. Our Site does not respond to web browser “Do No Track” signals.
We may use your IP address and information about the site pages you visit to gather broad demographic information, as well as information about your interests and behaviors, to gain a better understanding of our customers and Users. For example, information may be used to analyze and improve our site design and functionality.
HOW WE SHARE INFORMATION
We do not sell your personal information to anyone for direct marketing purposes, unless we first obtain your prior consent.
We may share your information with third parties for purposes such as:
To provide services to you or us, such as maintenance services, database management, fulfillment, web analytics, and improvement of the features or functionality; or to assist us in analyzing how our products and services are being used. We share only the information necessary for service providers to perform their services, and we require them to protect any personal information they may receive from us;
To Welldoc Inc. (“Welldoc”), which jointly operates ByramConnect and will directly receive your Personal Information collected by or uploaded to the ByramConnect account. Welldoc will use and share your information to manage and support the Site and its underlying technology, including using de-identified and aggregated information to improve the technology that supports ByramConnect. Welldoc’s use and sharing of your information will be consistent with this Privacy Policy, provided however, Welldoc may not use your information to advertise or market to you. Welldoc will be a third-party beneficiary of this Privacy Policy.
To comply with law, such as responding to court orders, requests by government agencies and law enforcement officials and other legal process;
To protect our legal rights, such as to defend against legal claims, enforce our Terms of Use or other agreements, or to obtain payment for products or services;
With your health plan or employer, if our services are part of a program or benefit that they offer to you, or to your health care provider(s) as part of our products or services. Any such disclosures will be made to the extent permitted by applicable law;
To state and federal regulatory agencies, auditors, lawyers, or other professional advisors.
To implement a transfer of business assets, such as in connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy.
Please note that if you use any bulletin board, chat room, comment posting feature, or other public communication service, forum, or feature offered through the Site, or post any information available for viewing by other Users, any of the information that you share will be visible to other Users. The information that you make available can be read, used, and collected by other Users to send you unsolicited messages outside of Byram Healthcare products and services and the Site. Byram Healthcare is not responsible for the manner in which the information that you decide to share will be used by other Users.
ANONYMOUS & AGGREGATE INFORMATION
We collect some information on an anonymous basis. We also may anonymize or de-identify the information we collect about you so that it can no longer be linked to you, and we may combine or aggregate this data, or engage service providers to do so on our behalf. We may use and share this data with third parties to perform data analytics and research, including to improve our products or services or develop new products or services.
OUR ONLINE PRIVACY POLICY FOR CHILDREN
Our products and services are not designed to attract children under the age of 13. We do not knowingly collect personally identifying information from anyone under the age of 13. Any information about a child under the age of 13 must be provided by that child’s parent or legal guardian. If you are the parent or legal guardian of a child under the age of 13 and become aware that the child has provided personal information through the Site without your consent, please notify us promptly using the contact information below. Please mark your inquiries “COPPA Inquiry.” If we become aware that a child under age 13 has provided us with personal information without parental/guardian consent, we will take steps to remove it.
SAFEGUARDING YOUR INFORMATION: OUR POLICY ON DATA PROTECTION AND SECURITY
We take reasonable steps to protect your personal information, which is any information that identifies you or could reasonably be linked to you. For example, a password is required to access your account and help to protect your account information. Please keep this password confidential. We also use encryption technology, called Secure Sockets Layer (SSL), to help protect personal information in certain areas of our Sites during transport across the Internet. The presence of SSL encryption may be indicated by https in the browser URL or the image of a closed lock or solid key in the browser window. These indications may not be present in mobile services that use SSL. Unfortunately, there is always some risk that an unauthorized third party may find a way around our security measures. We cannot guarantee that the Internet or any other technical system will be 100% secure or error-free. We are not responsible for the security of information you transmit over networks that we do not control, including the Internet and wireless networks. It is your responsibility to protect the security of your login information.
We maintain information about you in our business records while you are a customer or User, or until it is no longer needed for business, tax, or legal purposes. We have implemented encryption or other appropriate security controls to protect personal information when stored or transmitted by Byram Healthcare. Your information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. The Site is not intended for use outside of the United States. Nonetheless, if you are outside of the United States, by providing us with your personal information you agree to the processing of it in the United States as permitted by the laws of the United States.
YOUR CHOICES
We believe that choice in how and when you are contacted is key to customer satisfaction, so we offer several ways for you to update your contact information, change your preferences, or opt out of receiving marketing communications. If you are a current User, you may log in to your account to view your profile and access your account information. You may have the option to request changes to, or deletion of, certain account information. Below are some choices you may have:
Users may opt-out of receiving marketing emails by going to “My Preferences” in their account. Opting out of marketing emails related to ByramConnect will not stop emails notifying you of benefits or programs made available to you by your employer or health plan, which Byram Healthcare may make at the request of your employer or health plan.
You may unsubscribe to any marketing email by following the unsubscribe instructions in the body of the e-mail message.
You may unsubscribe to any text messages by following the unsubscribe instructions in any text message.
You may call our Customer Care Team for assistance with updating your contact information or in unsubscribing from certain communications.
You may write to us directly to: (a) update your contact information; or (b) request that we stop sending you marketing communications via mail, text, or e-mail. Written requests should be sent to our Chief Compliance Officer at: Byram Healthcare Centers, Inc., Attn: Chief Compliance Officer, 120 Bloomingdale Road, Suite 301, White Plains, NY 10605-1518We will try to implement your opt-out requests promptly, but you may still receive communications from us by email for up to 10 days and by mail for up to 60 days due to printing and mailing schedules.
Please note that if you use the Site there are certain messages you may not opt out of receiving, such as non-promotional email messages about programs or services you have registered for or certain administrative, technical, or safety notices about the Site or our products or services.
EMAIL AND TEXT COMMUNICATIONS
We may communicate, electronically or via telephone, including by SMS (text) with you about our programs, products, services, offers or general health information. We may communicate with you via unencrypted methods, such as by text or unencrypted email. You acknowledge and accept that communications by text or email involve some risk of unauthorized disclosure or interception of the contents of these communications. As explained above in “Your Choices,” you may customize your preferences for some communications, including delivery options, and update your contact information, including telephone number and email address. It is your responsibility to provide us with true, accurate, and complete contact information, and to make any changes to that information promptly. You understand that failing to update your contact information may delay or prevent us providing you with communications that rely on that contact information.
THIRD PARTIES AND LINKS
In the event that you provide your information to any third party via any Byram Healthcare website or any offer made available to you by Byram Healthcare, you understand that Byram Healthcare is not responsible for such third parties’ use or misuse of your information. You should review the privacy and information sharing practices of such third parties. Additionally, Byram Healthcare may offer links to or from the Site to other sites, so that you can conveniently visit our vendors and advertisers or locate other content likely to be of interest. We are not responsible for the content, practices or policies of sites operated by third parties and urge you to inquire about them before providing any personally identifiable information.
CALIFORNIA PRIVACY RIGHTS
We do not share Personal Information with third parties for their marketing purposes. Pursuant to California’s Shine the Light statute (Cal. Civ. Code Sec. 1798.83), if we do share Personal Information in such way, we will provide appropriate notice by updating this policy
In addition, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain other rights concerning their Personal Information. This section describes (1) the categories of Personal Information, collected and disclosed by Byram Healthcare through the Site, subject to California privacy law, (2) your privacy rights under California privacy law, and (3) how to exercise your rights.
When we use the term “Personal Information” in this section, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
If you are a California resident, please be aware that we collect, process, and maintain Personal Information to fulfill certain business purposes related to the Site. We will not collect additional categories of Personal Information or use Personal Information collected for additional purposes without providing you notice. Within the preceding twelve (12) months we and our service providers have and may collect, and you may consent to provide, the categories of personal information set forth below. We disclose each of these categories of Personal Information with our service providers, including Welldoc, for our business purposes (to enable the service providers to provide their services) and as otherwise described in the “How We Share Information” section above.
We may disclose each of these categories of Personal Information to our service providers and as otherwise described above. Additionally, certain advertisers may have used and disclosed Usage Information collected automatically from the Site, as described above in “Online Activity Tracking” and related to Google Analytics. Regardless of whether this a “sale” of Personal Information as defined by California law, we provide you the right to opt out of cookies, as described above.
Privacy Right | Description |
---|---|
Notice | You have the right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared. |
Access | You have the right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information. |
Data Portability | You have the right to receive the Personal Information you have previously provided to us. |
Erasure | You can request to have your Personal Information deleted from our servers and we will direct our service providers to do the same. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); (4) to otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information. |
If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to Privacy@byramhealthcare.com.You have a right not to receive discriminatory treatment by any business when you exercise your CCPA rights.
While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:
Please note that you do not need to create an account with us in order to make a request to exercise your rights hereunder.
In all cases, we will respond to your request within 45 days. However, where reasonably necessary, we may extend our response time by an additional 45 days, provided we send you notice of such extension first. We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.
We will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests, if determined by us to be unfounded or excessive (e.g. repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.
CHANGES TO OUR PRIVACY POLICY
We may make changes to our Privacy Policy from time to time. When we do so, we will post the revised Privacy Policy on the Site and change the “Effective Date”. Please check the Effective Date at the bottom of this page to determine if the policy has been modified since you last reviewed it. Your continued use of the Site after that date means you agree to this Privacy Policy and any changes to it.
CONTACT US
You may contact us at Privacy@byramhealthcare.com or write us at: Byram Healthcare Centers, Inc., Attn: Privacy Officer, 120 Bloomingdale Road, Suite 301, White Plains, NY 10605-1518.
Effective Date: : August 20th, 2021